Stormwater Phase II Final Rule September 2018

Pollution Prevention/Good Housekeeping Minimum Control Measure

his fact sheet profiles the Pollution Prevention/Good Housekeeping for Municipal Operations minimum control measure, one of six Tmeasures the operator of a Phase II regulated small municipal separate storm sewer system (MS4) is required to include in its storm water management program to meet the conditions of its National Pollutant Discharge Elimination System (NPDES) permit. This fact sheet outlines the Phase II Final Rule requirements modified December 9, 2016 and effective on January 9, 2017. It offers some general guidance on how to satisfy them. It is important to keep in mind that the small MS4 operator typically has a great deal of flexibility in choosing exactly how to satisfy the minimum control measure requirements in its NPDES permit.

United States Office of Water Factsheet 2.8 Environmental Protection Agency (4203) Pollution Prevention/Good Housekeeping Minimum Control Measure

Why Is Pollution Prevention/Good Housekeeping Necessary? he Pollution Prevention/Good Housekeeping for municipal operations minimum control Tmeasure is a key element of the small MS4 stormwater management program. This measure requires small MS4 operators to examine and subsequently alter their own actions to help ensure a reduction in the amount and type of pollution that: (1) collects on streets, parking lots, open spaces, and storage and vehicle maintenance areas and is discharged into local waterways; and (2) results from actions such as environmentally damaging land development and flood management practices or poor maintenance of storm sewer systems.

While this measure is meant primarily to improve or protect receiving water quality by altering municipal or facility operations, it also can result in a cost savings for the small MS4 operator, since proper and timely maintenance of storm sewer systems can help avoid repair costs from damage caused by age and neglect.

What Is Required? ecognizing the benefits of pollution prevention practices, the rule requires an operator of a Rregulated small MS4 to: . Develop and implement an operation and maintenance program with the ultimate goal of preventing or reducing pollutant runoff from municipal operations into the storm sewer system. . Include employee training on how to incorporate pollution prevention/good housekeeping techniques into municipal operations such as park and open space maintenance, fleet and building maintenance, new construction and land disturbances, and stormwater system maintenance. To minimize duplication of effort and conserve resources, the MS4 operator can use training materials that are available from EPA, their State or Tribe, or relevant organizations. . Determine the appropriate best management practices (BMPs) to meet permit requirements for this minimum control measure. Some program implementation approaches, BMPs (i.e., the program actions/activities), and measurable goals are suggested below.

What Are Some Guidelines for Developing and Implementing This Measure? he intent of this control measure is to ensure that existing municipal, State or Federal Toperations are performed in ways that will minimize contamination of stormwater discharges. EPA encourages the small MS4 operator to consider the following components when developing their program for this measure:

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. Maintenance activities, maintenance schedules, and long-term inspection procedures for structural and non-structural controls to reduce floatables and other pollutants discharged from the separate storm sewers. . Controls for reducing or eliminating the discharge of pollutants from areas such as roads and parking lots, maintenance and storage yards (including salt/sand storage and snow disposal areas), and waste transfer stations. These controls could include programs that promote recycling (to reduce litter), minimize pesticide use, and ensure the proper disposal of animal waste. . Procedures for the proper disposal of waste removed from separate storm sewer systems and areas listed in the bullet above, including dredge spoil, accumulated sediments, floatables, and other debris. . Ways to ensure that new flood management projects assess the impacts on water quality and examine existing projects for incorporation of additional water quality protection devices or practices. EPA encourages coordination with flood control managers for the purpose of identifying and addressing environmental impacts from such projects.

The effective performance of this control measure hinges on the proper maintenance of the BMPs used, particularly for the first two bullets above. For example, structural controls, such as grates on outfalls to capture floatables, typically need regular cleaning, while non-structural controls, such as training materials and recycling programs, need periodic updating.

What Are Appropriate Measurable Goals? The MS4 permit will specify any actions and deadlines that permittees must meet for permit compliance. The permit may also require permittees to develop measurable goals that guide implementation of MS4 chosen actions to meet permit requirements and to determine program effectiveness. The measurable goals, as well as the BMPs, should consider the needs and characteristics of the operator and the area served by its small MS4. The measurable goals should be chosen using an integrated approach that fully addresses the requirements and intent of the minimum control measure.

EPA has developed a Measurable Goals Guidance for Phase II MS4s that is designed to help program managers comply with any permit requirement to develop measurable goals. The guidance presents an approach for MS4 operators to develop measurable goals as part of their stormwater management plan. For example, an MS4 program goal might be to incorporate the use of road salt alternatives for highway deicing and reduce traditional road salt use by 50 percent in the first year of the permit term.

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For Additional Information

Contacts Your NPDES Permitting Authority A list of names and telephone numbers Most States and Territories are authorized to administer the for the U.S. EPA’s Office of Wastewater NPDES Program, except the following, for which EPA is the permitting authority: Management (Headquarters), each EPA • Guam • Midway and Wake Islands Regional Office, and State Offices is • District of Columbia • Massachusetts located at www.epa.gov/npdes/npdes- • Johnston Atoll • Northern Mariana Islands stormwater-program (click on “Contact • Idaho (until 7/1/2021, • New Hampshire Us” and then “Stormwater”). which is the date when • Puerto Rico Idaho becomes • New Mexico authorized to • implement the Trust Territories Stormwater NPDES • American Samoa program) Reference Documents • EPA’s Stormwater Web Site Phase II Final Rule Fact Sheet Series Stormwater Phase II Final Rule (64 FR 68722) ○ National Menu of Best Management Practices for Stormwater Phase II ○ Measurable Goals Guidance for Phase II Small MS4s ○ ○

Disclaimer: This information is guidance only and does not establish or affect legal rights or obligations. Agency decisions in any particular case will be made by applying the law and regulations to the specific facts of the case.

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